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When asked how he would typically line up the piping and valve
                   arrangements for conducting a negative test, Harrell described another method
                   for performing a negative test.  He explained that “[y]ou do it by leading
                   [bleeding] off back to Halliburton and up your drill pipe.  You pump seawater to
                   the end of your tail pipe and all the way back up to above your annular with
                   your spacer…You hold the mud in the riser with the annular closed…You have
                   seawater in the drill pipe and you have seawater in the kill line and either one
                   would be seeing the same pressure…”
                                                            214

                          Leo Lindner, an employee of MI‐SWACO, testified that on the morning of
                   April 20, 2010, he had two separate conversations regarding the negative
                   pressure test, one with Kaluza and one with Morel.  Lindner stated:

                          He [Kaluza] wanted to go over the method by which the rig had been
                          doing its negative test and displacing.  I explained – I explained it to him.
                          He seemed satisfied with it.  Shortly after that, I was called by Mr. Brian
                          Morel.  We had basically the same conversation.  He seemed satisfied with
                          it.  He informed me they were going to be displacing further down the
                          hole than usual.  Usually itʹs 300 feet below the mud line, but this was
                          going to be at 8,367 feet [3,367 below the mud line].  I left the office and I
                          make my calculations.  I type up a displacement procedure.
                                                                                         215

                          Lindner’s procedure specifically instructed, as step two, to “[d]isplace
                   choke, kill, and boost lines and close lower valves after each.”   The procedure
                                                                                    216
                   did not instruct the personnel to re‐open the choke and kill lines, which would be
                   necessary to perform a negative test on either line.  In any event, Lindner
                   presciently noted at the end of the procedure that “[g]ood communication will be
                   necessary to accomplish a successful displacement.  If you are not sure, stop and
                   ask.”
                        217

                          The only instruction given to the rig personnel in evaluating the negative
                   test was to monitor the well for no flow.  No instructions were given to re‐open
                   the choke and kill lines, to monitor drill pipe pressure, or to evaluate and
                   investigate any pressure differentials.  Testimony and interview notes from BP



                   214  Harrell testimony at 33.
                   215  Lindner testimony at 272.
                   216  BP‐HZN‐MBI00133083.
                   217  Id.


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